# SOFTWARE MANSION RADON IDE PRIVACY POLICY

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#### Version 5.0, effective as of July 7, 2025

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In this Privacy Policy, we describe the types of data, including Personal Data (collectively, “data”), that we and our associated companies collect from you when you use Software Mansion Radon IDE Website and certain Software Mansion Products and services as described in this Privacy Policy (collectively, our “services”), how we and our associated companies use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The respective latest version of the Privacy Policy at the point of time of the purchase or registration of a Software Mansion Software Product (whichever occurs later) shall apply. The data controller is Software Mansion S.A., a joint stock company with its principal place of business at ul. Zabłocie 43b, 30-701 Kraków, Poland, entered in the register of businesses conducted by the District Court in Kraków for Kraków-Śródmieście, XI Commercial Division of the National Court Register with KRS number 0000961952, NIP 6793131302, REGON 364909814.

## Definitions

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The following definitions are used throughout this Privacy Policy:

**Software Mansion Software Product**. Any software product owned or created by Software Mansion and provided under Software Mansion' Subscription Agreement, including but not limited to Radon IDE. This may include, but not be limited to, code that extends the functionality of a Software Mansion Software Product (e.g., a “plugin”). Any such code is governed by its own terms and conditions and privacy policy. This also includes any Products provided free-of-charge, such as alpha and beta version and/or early access of Software Mansion Software Products.

**Software Mansion Downloadable Software Product**. Any Software Mansion Software Product that can be downloaded and installed on a device, offered on Software Mansion Radon IDE Website.
Software Mansion Software as a Service. Any Software Mansion Software Product that is offered as a hosted solution, where the software is installed and maintained by Software Mansion and provided to you as a service, offered on Software Mansion Radon IDE Website.

**Software Mansion Radon IDE Website**. [www.ide.swmansion.com](https://ide.swmansion.com).

**Software Mansion Radon IDE Portal**. [www.portal.ide.swmansion.com](https://poratl.ide.swmansion.com).

**Software Mansion Account**. An account you create and which Software Mansion may use in communicating with you or providing Software Mansion Products to you, which contains your first name, last name, email address, username and if uploaded voluntarily, your photograph or another avatar. Your account is accessed via a username and password and can be used to manage your Personal Data.

**Software Mansion Terms of Use** means Software Mansion Subscription Agreement, Software Mansion Terms of Use for a product, or other agreements you have in place with Software Mansion covering Software Mansion Products.
Software Mansion Software Products, Software Mansion Downloadable Software Products and Software Mansion Website may be collectively referred to as "**Software Mansion Products**".

**Personal Data** means any data relating to an identified or identifiable natural person.

All other capitalized terms used in this Privacy Policy shall have the same meaning as defined in article 4 GDPR (such as personal data, controller, processor, data subject, and others), unless defined otherwise in this definition clause.

## Why We Collect Data and What We Collect

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We collect data for various reasons, such as:

a) To provide you with software, services, or information. We may collect data, including your Personal Data, which are required to provide you with the software, support, and services, including checking for license validation and updates, provision of support, reporting of issues and bugs, and other processing connected with the use of Software Mansion software, services, or information. We may use collected data in our development and testing of products and services. You explicitly fill in the Personal Data required for you to receive the software, support, or services, whether you purchase or use Software Mansion Products, use our support forums, sign up for a Software Mansion Account, register for a webinar, participate in a survey, and/or subscribe to receive marketing and/or technical information and content, or this data is collected in the course of use of Software Mansion Products. We may use third-party service providers, acting as data processors, to assist us in providing Software Mansion Products to you or in our operations. For example, we may use third-party service providers to provide data storage and backup services. With your consent, your Personal Data may also be transferred to third-party service providers, acting as separate data controllers, who provide products and services complementary to Software Mansion Products (further data processing performed by these service providers is governed by their privacy policies). The legal basis for this data processing is the performance of a contract between you and us.

Our Service allows customers to submit, manage or otherwise use content relating to others, such as end users of applications built and managed through the Service or their employees and contractors (“Customer Data”). We use such Customer Data as a processor, meaning we process such Customer Data on behalf of and under the instructions of the relevant customer, in accordance with our data processing addendum available on the Website. This Privacy Notice does not apply to such processing; if you believe your personal information has been included in any Customer Data, we recommend you read the Privacy Notice of the respective customer.

_Device information and IP addresses._ When you visit the Radon IDE Website or use the Radon IDE Portal, we collect your IP address and other data through tracking technologies like cookies, web beacons, and similar technologies. We also collect IP addresses when you make requests to our APIs and in our server logs. We use this information to understand how customers are using our platform, who those customers are (if they are a company and the IP address is associated with that company), what country they are logging in from (for analytics and export control purposes), and to help improve the navigation experience. You can learn more about cookies in the section titled “Cookies and Tracking Technologies” below.

b) To protect us from piracy and unlawful use of our software or services. We may collect data which are required to protect us from any piracy, unlawful, or unauthorized use of our software or services, or which are necessary to ensure the security of our software or services, including both Personal Data provided by you (see above) and data collected in the course of use of Software Mansion Products. The legal basis for this data processing is Software Mansion' legitimate interest in protection from piracy and unlawful use of Software Mansion software and services.

c) To improve our offerings based on usage. We may collect data based on your use of Software Mansion Products and services, and we do not associate these data with your name. We use these data to better understand the usage patterns of our products and the behaviors of our collective audience. At times we may share this information in aggregated anonymous form with third parties. Collection of data based on your use of Software Mansion Downloadable Software Products is done only if you permit it. The legal basis for this data processing is our legitimate interest in improving our software and services.

d) For internal evidence of Software Mansion and to protect the rights and interests of Software Mansion and other users. We may collect data which are required to keep evidence of provision of software and services to you, of any communication between you and us, of your contact details, of your use of our software and services, of any payments or refunds, and of any issues or disputes between you and us. We may use and disclose these data where we believe, in our sole judgment, that it is legitimate and appropriate to do so to protect our rights and interests and the rights and interests of other users of Software Mansion Products or services, or where we believe there has been a violation of this Privacy Policy that could affect the interests of Software Mansion or its customers. The legal basis for this data processing is our legitimate interest in keeping internal evidence and protecting the rights and interests of us and other users.

e) To promote and market our products and services. We may use feedback that you provide voluntarily on our products or services. As permitted by applicable law, we may use this in the form of quotes or in other ways in accordance with the applicable Terms of Use. We also may use data that we collect and aggregate to assist us in determining appropriate marketing and advertising for our products and services. In doing so, we may share anonymous aggregated data with third parties to assist us with these efforts. With your consent or if permitted by applicable law, we may also use your contact details to send you commercial communications about our products and services. We also may use third-party service providers to assist us with our email marketing; in that case, the third-party service provider will have access to your email address, your name, and other information necessary to engage in the marketing. Such third-party service provider will act as a data processor and will not use your Personal Data for any other purpose. The legal basis for this data processing is our legitimate interest in promoting and marketing our products and services.

f) To fulfill legal duties stipulated by accounting, taxation, and other laws. We may use and disclose your Personal Data where required by law, such as in keeping and disclosing our accounts, in keeping and disclosing our tax records, and in response to a court order, valid subpoena, or other legal process. The legal basis for this data processing is our compliance with our legal obligations.
You may object to the processing of your Personal Data for the purposes b) to e) at any time.

Categories of data involved in data processing include:

- names,
- email address,
- phone number,
- username,
- password,
- photograph (if voluntarily provided),
- cookies,
- IP address,
- physical address,
- information about subscription and payments,
- tax ID,
- data about usage of Software Mansion Products and services,
- comments, voluntarily provided feedback, and any data provided in survey responses,
- data in issue reports pertaining to Software Mansion Products and services.

Where appropriate, we will prompt you to give us your consent to the collection and processing of your data as described above. This may happen within Software Mansion Products, on Software Mansion Radon IDE Website, or in another environment set up by Software Mansion, always in a clear and conspicuous manner. You can manage your Personal Data and opt-outs as described in the Transparency section below.

**Data we process from our website and interactions**

When you visit our website we may collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our Services, and to improve navigation experience on our pages. You can learn more about cookies in the section titled “Cookies and Tracking Technologies” below.

**Cookies and Tracking Technologies**

We may use common information-gathering tools such as cookies, web beacons, pixels and other similar tracking technologies to automatically collect information as you navigate our websites, your account or when you interact with emails we send to you.

**Cookies**

A cookie is a small piece of data stored on your device when you visit a website. Cookies allow us to identify your device as you navigate our websites or your account. This makes navigating and interacting with our websites or your account more efficient, easy and meaningful for you.
By themselves, cookies do not identify you specifically. Rather, they recognize your web browser. So, unless you identify yourself specifically to us, like signing into your account, we don't know who you are just because you visited our website. We use persistent cookies. Session cookies are cookies that disappear from your computer or browser when you turn off your computer. Persistent cookies stay on your computer even after you've turned it off. These cookies enable core functionality such as security, network management, and accessibility and are necessary for our websites to function properly.

## Children

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Our products and services are not designed for and are not offered to children under the age of 13. If we discover that a person under the age of 13 has submitted information directly to us, we will endeavor to delete the information from our systems.

## Sharing

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Collected Personal Data are shared based on the Subscription Agreement, Terms of Use of a product or service in use, and this Privacy Policy.

According to Software Mansion Terms of Use covering a particular product or service, as part of the product or service functionality, collected Personal Data may be shared with other representatives of your company.
We may share your Personal Data with certain third parties which help us provide you with Software Mansion Products or services, or to run our business, for example to providers of data storage and backup services. We may also share your Personal Data with individual representatives of your company.

Your Personal Data may also be shared with other organizations or individuals if we have obtained your consent to do so.
We may also share your Personal Data with certain third parties if we are obliged to do so under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing is necessary to achieve the purposes defined above (especially with government bodies or with parties harmed as a result of violations of applicable laws).
To adhere to the requirements of the California Consumer Privacy Act (CCPA), we hereby notify you that Software Mansion will not a) retain, use, sell, or otherwise disclose any Personal Data for any purpose other than to provide the Products and services specified in the Subscription Agreement; or b) retain, use, sell, or disclose such Personal Data outside of the direct relationship between Customer and Software Mansion; or c) use Personal Data other than as described within (i) the Software Mansion Privacy Policy available at ide.swmansion.com/privacy-policy; (ii) the Software Mansion User Agreement available at [ide.swmansion.com/legal](https://ide.swmansion.com/legal) (iii) the Software Mansion Purchase Terms available at [ide.swmansion.com/legal/purchase-terms](https://ide.swmansion.com/legal/purchase-terms) or (iv) any other specific agreement you may have entered into with Software Mansion.
YouTube API Services. We may display YouTube videos on the Software Mansion Radon IDE Website using API Client. The API Client uses [YouTube API Services](https://developers.google.com/youtube/terms/developer-policies#definition-youtube-api-services). By interacting with the video, you agree to [YouTube’s Terms of Service](https://www.youtube.com/t/terms) and acknowledge [Google’s Privacy Policy](https://policies.google.com/privacy). By interacting with Software Mansion Radon IDE Website, you acknowledge our Privacy Policy.
Information we collect. The API Client collects and uses data from YouTube API Services. It also collects information from your devices you use to access Software Mansion Radon IDE Website to the extent of your tracking preferences in accordance with our Cookie Notice.
How we use your information. We use the data collected from the API Client to display the YouTube videos through the API Client. YouTube can access information about the videos you viewed on the Software Mansion Radon IDE Website and display advertisements based on your viewing history. YouTube ad settings are available on this link. We use first and third party cookies to enhance and personalize your website experience.
Sharing. We may share authorized data with Google (including YouTube).
Your rights. You can manage or revoke Google's access to your data via Google Security Settings.

When you submit a query through our Radon AI Tool, the query will pass through our servers, but we will not make a copy thereof nor keep it in any of our databases. We will, however, save and process any feedback, in the form of thumbs up or thumbs down, that you give to the response you received from Radon AI Tool. We will not access the content of the databases itself or the information you manage through the Service.

## Security

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To secure your Personal Data, our products and services are designed with security and privacy in mind.
We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.
We review the processes of Personal Data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your Personal Data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your Personal Data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

## Location of Your Information

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Servers or services that contain Personal Data are located mainly in the US and EU, however Personal Data may be subject to cross-border transfers conducted by our third-party providers, including but not limited to Vercel.

## Third-Party Links

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Software Mansion Radon IDE Website may contain links to other websites provided by third parties not under Software Mansion control. When following a link and providing information to a third-party website, please be aware that Software Mansion is not responsible for the data provided to that third party. This Privacy Policy only applies to Software Mansion Radon IDE Website, so when you visit other websites, even when you click on a link posted on Software Mansion Radon IDE Website, you should read their own privacy policies.

## Data Retention, Withdrawal of Approval, Access to Data and Your Rights

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If at any time you choose to cease using Software Mansion Products, you may ask for your Personal Data to be removed from our servers by sending a request to legal@swmansion.com. After the Personal Data removal, we may keep pseudonyms of your Personal Data solely for a record about the data removal. Generally, we retain your Personal Data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of Software Mansion Terms of Use and/or Privacy Policies. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes if this is mentioned in a Software Mansion Terms of Use or consent text accepted before the Personal Data collection. These backups will not be accessible as separately delineated information. We may store Personal Data pertaining to a customer or user for as long as they are entitled to a license or usage of Software Mansion Products. Further, we may keep the data to protect ourselves from damage in case of litigation in accordance with the current legislation. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for the retention of any of your data.

You are responsible for the correctness of the Personal Data you provide to us. We expect you to check the Personal Data you provide to us and if any inconsistency takes place, update your Personal Data or report the inconsistency to Software Mansion.
As permitted by applicable law, EU residents may request a copy of the information that we hold about them. To do so, contact legal@swmansion.com. We may charge a fee in accordance with applicable law for this service.
Moreover, as set out in locally applicable Personal Data protection law, you may have the right to: (i) request access to your Personal Data; (ii) request rectification of your Personal Data; (iii) request erasure of your Personal Data; (iv) request a restriction on the processing of your Personal Data; (v) request Personal Data portability; or (vi) object to the processing of your Personal Data.

- **Right of Access**. You may have the right to obtain from us a confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, to request access to your Personal Data. The information about Personal Data processing includes the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom your Personal Data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your Personal Data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.

- **Right to Rectification**. You may have the right to obtain from us the rectification of inaccurate Personal Data. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data made complete, in particular by providing a supplementary statement.

- **Right to Erasure (Right to Be Forgotten)**. Under certain circumstances, you may have the right to require us to delete your Personal Data.

- **Right to a Restriction of Processing**. Under certain circumstances, you may have the right to require us to restrict the processing of your Personal Data. In this case, the respective Personal Data will be marked and may only be processed by us for certain purposes.

- **Right to Personal Data portability**. Under certain circumstances, you may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these Personal Data to another entity.

- **Right to Object**. Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data.
  These rights can be exercised via the email address legal@swmansion.com.
  You may also contact Software Mansion to get up-to-date information about your Personal Data processing and any Personal Data recipients.

You may lodge a complaint related to the processing of your Personal Data with the competent data protection supervisory authority, i.e. in Poland, the President of the Office for Personal Data Protection. A complaint can be filed by traditional mail to the following address: ul. Stawki 2, 00-913 Warszawa, or by email:kancelaria@uodo.gov.pl. You can also obtain more detailed information (including current phone numbers) at the following web address: https://uodo.gov.pl/.

## Changes to this Policy

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This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on Software Mansion Radon IDE Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Data we have previously collected from you, we will endeavor to provide you with an advance notice of such change by highlighting the change on Software Mansion Radon IDE Website.
